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SECR reporting for logistics and transport — UK guide

Logistics is the SECR sector where scope 1 (your own fleet) and scope 3 (sub-contracted hauliers, last-mile delivery, customer freight) are both materially large — and where data is fragmented across telematics, fuel cards and third-party invoices.

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SECR at a glance

~11,900

UK organisations in scope

Estimated companies and LLPs covered by SECR

£36M / £18M / 250

The size thresholds

Meet two of three — turnover, balance sheet, employees — and you're large

Unlimited

Fine on conviction

Leaving SECR out of the Directors' Report is a criminal offence under s.415 CA 2006

£1,500 / £7,500

Late-filing penalties

Maximum Companies House penalty for private / public companies if you delay the accounts

Thresholds and penalties are set out in the Companies Act 2006 and the Companies (Directors' Report) and LLP (Energy and Carbon Report) Regulations 2018. The SECR thresholds did not change in the April 2025 company-size uplift, so a company now classed as medium-sized can still be in scope.

If you run a UK haulage, freight, courier or third-party logistics business meeting the SECR thresholds (£36M+ turnover, £18M+ balance sheet, or 250+ employees), this guide covers what to file and where most logistics businesses get it wrong.

SECR challenges specific to logistics and transport

Four problems generic SECR templates don't handle for transport businesses:

  1. Telematics data quality. Modern HGV and LCV fleets generate per-vehicle, per-trip fuel consumption from telematics — but the data lives in Microlise, Verizon Connect, Webfleet, Geotab or whatever platform your operator uses. Pulling, cleaning and reconciling it with fuel card data eats consultant time.
  2. Fuel card vs depot bunker split. Most fleets fuel partly through fuel cards (Allstar, Fuelgenie, Texaco) and partly through on-site depot bunkers. Scope 1 has to account for both without double-counting and without missing the bunker fuel that doesn't appear on a card statement.
  3. Sub-contracted haulier emissions are scope 3, not scope 1. A lot of logistics businesses run a mixed fleet of owned tractors, owned trailers pulled by contracted drivers, and fully sub-contracted runs. The operational control test matters here — getting it wrong distorts your scope 1 by 30–60%.
  4. Refrigerated trailer F-gases. Refrigerated road transport runs on either electric standby with diesel auxiliary or pure diesel-driven refrigeration units. F-gas leakage from R-452A, R-404A and R-134a units is material scope 1 emissions that fleet teams often don't track.

Typical scope 1 emissions in logistics

Scope 1 is direct emissions from sources you own or have operational control over. For UK logistics this typically means:

  • Diesel — owned HGV fleet (rigids, artics, drawbar combinations)
  • Diesel and petrol — owned LCV / van fleet (transit, sprinter, courier vans)
  • Diesel — refrigerated transport units (transport refrigeration units / TRUs)
  • Diesel — yard tractors, shunters, terminal tractors
  • Diesel and LPG — forklift fleet
  • Natural gas — depot space heating, workshop heating, vehicle wash facilities
  • F-gas refrigerant leakage — TRUs, chillers in cold-storage warehouses, comfort cooling
  • AdBlue — note: AdBlue itself is not emissions-counted (it reduces NOx, not CO₂), but track it as a fuel-correlated data quality check

The single most-missed source in logistics SECR: F-gas leakage from refrigerated trailers and cold-storage warehouses. Fleet engineers log kg of refrigerant added in service reports.

Typical scope 2 emissions in logistics

Scope 2 is purchased energy. For most logistics businesses this is grid electricity for:

  • Depot and warehouse lighting and power
  • Cold storage and chilled warehousing (electric chillers, sometimes ammonia industrial refrigeration with electric compressors)
  • EV charging infrastructure — increasingly material as fleets electrify the LCV side
  • Office HQ energy

Cold-storage operators have grid electricity loads dominated by refrigeration — often 60–80% of total electricity use. The market-based vs location-based question (REGOs, green tariffs, PPAs) matters more here than in most sectors.

Scope 3 considerations for logistics

Scope 3 is voluntary for SECR but is the largest single emissions source for most logistics businesses — so much so that excluding it makes the report look incomplete to customers who file CDP or CSRD.

The relevant scope 3 categories for logistics:

  • Sub-contracted hauliers — this is the critical one. If you sell freight to a customer and sub-contract the actual driving to another haulier (you don't own the tractor or the driver), the haulier emissions are scope 3 to you (purchased transportation services) and scope 1 to the haulier
  • Category 9 — Downstream transportation — applies where you sell the freight service and the customer pays; allocation depends on operational control
  • Category 6 — Business travel — sales and operations team travel
  • Category 7 — Employee commuting — significant for distributed depot workforces
  • Customer-collected freight — last-mile customer pickup is technically scope 3 cat 9

Spend-based estimation works for year 1, but customers increasingly demand activity-based scope 3 — kg-CO₂e per tonne-km, calculated from manifests, fuel data and DEFRA factors.

Common mistakes logistics businesses make

  1. Including sub-contracted haulier emissions in scope 1 — they're scope 3 (purchased transportation) unless your contract gives you operational control over the asset
  2. Missing TRU diesel — refrigerated trailer fuel often runs through a separate fuel tank with separate metering, not counted in main tractor diesel
  3. Forgetting F-gas refrigerant leakage from chillers and TRUs
  4. Using telematics distance-based estimates instead of actual fuel-card data when both exist — the fuel-card data is authoritative
  5. Double-counting depot bunker fuel and fuel-card fuel for vehicles that fuel at both
  6. Not splitting AdBlue from diesel in supplier invoices that bundle them
  7. Reporting only tCO₂e without tCO₂e per tonne-km or per vehicle-km — the industry-standard intensity ratio

Trade body context — Logistics UK and RHA

Logistics UK (formerly the Freight Transport Association) publishes the Logistics Carbon Reduction Scheme and annual sector emissions benchmarks. Reference Logistics UK's data and the Road Haulage Association's (RHA) decarbonisation guidance in your narrative section.

For shipping and freight forwarding, the Smart Freight Centre's GLEC Framework is the global standard for activity-based scope 3 calculation — auditors expect to see it referenced for sub-contracted emissions. For fleet decarbonisation pathways, the Department for Transport's Future of Freight strategy provides the regulatory context for your narrative.

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